Re: AB-771, Abandonment of Ellsworth Drive: Approve Only With Condition: NO PLASTIC TURF OR RUBBER SURFACES
December 2020
I am pleased to provide this written comment in my capacity as a long-time resident of Montgomery County and the president of the nonprofit National Center for Health Research. I have lived in Montgomery County for almost 30 years and raised my children here. I am proud to live in a county whose leadership cares about our planet, the environment of our communities, and the health of our family members.
I was shocked to hear at the recent hearing that some county officials may believe that the safety of artificial turf is not germane to the Abandonment of Ellsworth Dr. The criteria for abandonment is clear in the Montgomery County Code: abandonment must benefit the public, not just small groups of interested parties. The principles that are key to the abandonment provisions are the health, safety, and well-being of the public. Synthetic turf would not be installed on Ellsworth Dr. unless limited abandonment is approved, so the applicant’s planned use of artificial turf if Ellsworth is abandoned is clearly germane to the abandonment decision. The space currently has significant public use, so the County is responsible for ensuring that the public is protected if Ellsworth is abandoned.
I am a scientist trained at Yale School of Public Health, I am widely published in the medical and public health literature. I was formerly Chair of the Women’s Health Promotion Council for the State of Maryland, and I have testified about the risks of artificial turf and playground surfaces at federal, state, and local hearings and meetings in this area and across the country. I am very knowledgeable about the risks that the lead and toxic chemicals in artificial turf pose to our children and families, and how directly germane they are to the proposed abandonment.
Because abandonment must benefit the public good, I strongly urge you to condition approval of the abandonment of the subject portion of Ellsworth Drive on Foulger-Pratt’s providing a surface other than artificial turf or artificial rubber products such as PIP. Artificial turf may be green, and rubber surfaces may look attractive, but they are a hazard to human health and bad for our environment.
It makes no sense for our communities to restrict plastic bags in grocery stores or plastic straws in restaurants and then add to local and global pollution by covering huge areas with plastic grass or rubber surfaces, both of which are made from petroleum and are being dumped when they deteriorate, rather than being recycled.
I’m an epidemiologist currently focused on Covid-19 issues that have turned our lives upside down in Montgomery County, but when Covid-19 is a distant memory we would still be living with the harm caused by artificial turf and rubber surfacing if our county doesn’t get smarter about these decisions. A list of some (but not all) of the ways that artificial turf or rubber surfaces would harm the public if used on Ellsworth Drive is below:
- Artificial turf contains lead as well as chemicals that disrupt hormones, and as a result can exacerbate early puberty, obesity, asthma, and attention deficit disorder. Over the long-term, they can be carcinogenic. As the plastic blades degrade with wear and exposure to the sun, the lead and chemicals would get into the air, into nearby land, and into Sligo Creek. These chemicals include PFAS, also known as “forever chemicals” because they aren’t biodegradable. Lead can cause permanent cognitive damage, and once it is in the environment it lasts for decades.
- When dogs, squirrels, or other animals relieve themselves on what they think is grass, bacteria is likely to fester. A local college student almost lost her leg – and her life – as a result of an infection with flesh-eating bacteria that resulted from her playing Frisbee on artificial turf.
- Artificial turf is a petroleum-based product, with polypropylene backing and polyethylene blades of “grass.” Rubber is also petroleum-based; it is made from latex from a rubber plant, but mostly from petroleum. These surfaces get very hot – on a pleasant sunny summer day, when the air is 85 degrees, the temperature from artificial turf or rubber surfaces is usually 140-160 degrees Fahrenheit – or even hotter. (Imagine what happens when the temperature is in the 90’s for weeks, as it was this past summer.) The heat retained by these petroleum products contributes to heat exhaustion for anyone spending time on these surfaces. In addition, these surfaces can burn, creating a fire hazard. Although the surfaces can be doused with flame retardants to reduce (but not eliminate) the chance of a fire, flame retardants are also toxic chemicals, and would also run off into Sligo Creek.
- Artificial turf and rubber surfaces are not designed for traffic — not even for farmers’ market trucks. Those trucks would tear it up, loosen it from the pavement, and hasten disintegration of plastic blades of artificial grass, plastic backing, and the glue. That too would end up in Sligo Creek. Meanwhile, the storm water management system for Ellsworth Drive was not designed to filter plastic particles or chemicals. It is likely to be overwhelmed, resulting in high levels of these pollutants in Sligo Creek.
- After a few years, when these surfaces have deteriorated or torn, how will the county deal with disposal? Artificial turf is not recyclable because of the mixture of different kinds of plastic. Used artificial turf and synthetic rubber surfaces are usually dumped or it go into a landfill. (Seehttps://www.theatlantic.com/science/archive/2019/12/artificial-turf-fields-are-piling-no-recycling-fix/603874/) How often would the turf need to be replaced and where would the old turf go since it can’t be recycled? This is obviously a big problem that is relevant to artificial fields at schools and parks as well, but in this case, the county has a specific responsibility regarding whether to abandon Ellsworth Drive and allow toxic materials to be used in an area that is supposed to be enjoyed by the community.
Moreover, the Planning Board required, as a condition of its approval of plastic turf, that the developer submit an alternate proposal. They apparently have not done so; in fact, their comments at the recent public meeting urged the County to ignore the public health concerns about artificial turf expressed at the meeting by many citizens of Montgomery County. At the very least, an alternative proposal should be required and discussed by the public before any approval occurs.
In conclusion, Montgomery County is making laudable efforts to reduce the use of toxic chemicals, lead, tire crumb, and other dangerous materials. As presented before the County by Foulger-Pratt’s plan, AB-771 would move the county in the opposite direction, by intentionally giving up public land that is going to be used in a way that is dangerous to the public health and harmful to our environment.